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The "Withdraw from contract here" button – a new mandatory feature for online stores and marketplaces from June 2026

From 19 June 2026, online stores and platforms selling to consumers will be required to implement a two-step digital withdrawal mechanism. The draft amendment to the Consumer Rights Act [1] introduces an obligation to display a visible "Withdraw from contract here" function (e.g. button) – accessible in the same interface where the transaction was concluded.

This is not only a technical requirement. It is a clear legislative signal about the direction of enforcement: the right to withdraw from an online contract must be as easy as the purchase itself.

What does the new obligation require?

Under the amendment, traders are obliged to provide a visible "Withdraw from contract here" function, available in the place where the transaction was concluded – e.g. on the store's website, or in the mobile application – within or outside of the customer account panel.

Specifically:

· The button must be easy to locate and access and placed in the same interface in which the contract was concluded.

· The button description must clearly indicate its purpose so that consumers immediately understand that clicking it initiates the withdrawal process. The wording should be ‘Withdraw from contract here’ or other equivalent.

· The button must be available throughout the entire withdrawal period, so as a rule, 14 days from concluding the contract or receiving the goods.

· Consumers must be able to decide whether they are withdrawing from the contract in whole or in part (e.g., by selecting specific goods or services).

· The function cannot be temporarily disabled or made technically difficult to use.

· The store’s terms and conditions must clearly explain where the withdrawal function is located within the interface.

The 'withdrawal function' does not replace existing methods of cancelling a distance contract, i.e. consumers can still exercise this right via, e.g. email or post (if available).

Who does this apply to?

The new obligation applies to all distance contracts concluded between consumers and traders via online interfaces. This covers any B2C sales online including via online stores, marketplaces and mobile applications. The new rules apply not only to the sale of goods but also to provision of services, including contracts for digital content and services.

What does the withdrawal process look like?

The new solution is designed as a two-stage process to be as simple and intuitive as possible. 

Clicking a ‘Withdraw from contract here’ button should activate a simple online form, including a statement of withdrawal. The form should be limited to information needed to identify the order, such as:

· customer name and surname

· data identifying the contract (e.g. order number)

· information how the trader will provide the consumer with electronic confirmation of the withdrawal statement.

Crucially, the consumer does not need to give a reason for withdrawing – same as currently, the right remains unconditional and cannot be made dependent on explanations or additional formalities.

Stage 2 - Confirmation

There must also be an easily accessible withdrawal confirmation function – e.g., a ‘Confirm withdrawal’ button (or equivalent). This is to ensure that the consumer’s decision to withdraw is an informed one.

Practical considerations when implementing the withdrawal function

In practice, implementing the “Withdraw from contract here” function is less about adding a single button and more about aligning legal requirements with existing business and IT processes.

In our experience, the following key issues require early attention:

1. The withdrawal function must work across different customer journeys. In practice, this means that consumers who placed their order via a customer account must be able to find the button within the account itself. For those who purchased online as a guest, it means avoiding solutions that require mandatory login or exclude certain users from accessing the withdrawal flow.

2. Order structure matters. Where a single order may include multiple products, potentially sourced or fulfilled in different ways, the withdrawal function should allow consumers to clearly indicate the scope of withdrawal. The law allows withdrawal from the entire contract or only selected items, and the interface should reflect this flexibility without forcing the consumer into unnecessary or repetitive steps.

3. Data requirements should remain proportionate. The withdrawal form should be limited to information strictly required to identify the contract and confirm receipt of the withdrawal statement. Requests for additional data (e.g., bank account details) should be optional and clearly justified, particularly where the original payment method does not require such information.

4. Confirmation and traceability are key. Once the consumer submits and confirms the withdrawal, the trader must ensure that a confirmation is sent without undue delay on a durable medium, clearly documenting the content of the withdrawal and the date and time of submission. Automating this step significantly reduces operational risk and disputes.

5. Existing processes and documentation must be updated consistently. Introducing the withdrawal function typically requires changes not only at interface level, but also in terms and conditions, internal workflows and customer communication. From a compliance perspective, inconsistencies between the interface and contractual documentation are likely to attract regulatory attention.

Overall, regulators are increasingly focusing on whether the withdrawal right can be exercised in practice and without friction, rather than on formal declarations alone. Businesses that treat the withdrawal button as part of a broader user journey, rather than a standalone legal feature, are best positioned to mitigate legal risk.

How is this being implemented across Europe?

For businesses operating across multiple jurisdictions on a single interface, the withdrawal button introduces an additional layer of complexity. While the core obligation is harmonised at EU level, local implementation approaches may differ in detail, creating tension between maintaining a consistent user experience and addressing jurisdiction-specific expectations. In practice, the key question is not whether differences will exist, but how they should be managed within one system.

It is far more effective to address these questions early, with legal, product and technology teams working closely together, than to try to adapt an established interface later on.

The common thread running through all these implementations is the same logic already visible in UOKiK's dark pattern proceedings: the user must actually be free to exercise their rights without barriers.

Next steps

In practical terms, the withdrawal button reflects a broader shift in regulatory expectations. Consumer watchdogs are increasingly looking at how consumer rights work in reality, not just how they are described in legal documents. Where the withdrawal path is harder to navigate than the purchase journey, this is likely to be seen as a compliance issue rather than a design choice.

With the 19 June 2026 deadline approaching, businesses should treat the withdrawal button as part of the overall customer experience, ensuring that interfaces, internal processes and both contractual documentation and online communications are aligned so that consumers can withdraw at least as easily as they entered into the contract.

If you would like to discuss how these requirements could affect your platform or customer journey in practice, we would be happy to explore this further.

Authors: Monika Hughes, Karina Balcer-Kopka, Natalia Wysokińska-Ćwiek, Bird & Bird